Since July 29, 2026, a foreign cosmetics brand can change its domestic responsible person in China without the old partner’s consent. NMPA Announcement No. 70 of 2026 dropped the sealed consent letter, and the court judgment that stood in for it, from the file. The brand now signs its own notarized authorization for the new partner, and the old one signs nothing.
It matters because the responsible person is usually your distributor. For five years, a distributor on its way out could freeze your filings by refusing to stamp one letter. It can’t anymore.
A product changing its domestic responsible person no longer submits the old responsible person’s sealed consent letter or a judgment proving the change. It submits the notarized authorization letter, the product list and the new responsible person’s commitment to take on all the old one’s responsibilities, including for products already on the market. Source: National Medical Products Administration (国家药监局), Announcement No. 70 of 2026, item 8, July 2026. https://www.nmpa.gov.cn/xxgk/ggtg/hzhpggtg/jmhzhptg/20260729115807198.html
Signed July 28, it took effect on publication the next day and overrides any older NMPA document that disagrees.
What the responsible person does, and why your distributor has the job
Any foreign brand that registers or files cosmetics in China has to name a Chinese company to act for it. The rules call it the 境内责任人, the domestic responsible person.
An overseas registrant or filer must appoint a Chinese enterprise legal person as domestic responsible person, to file in its name and assist with adverse reaction monitoring and recalls. Source: State Administration for Market Regulation (市场监管总局), Cosmetics Registration and Filing Measures, Order No. 35, article 8, January 2021. https://www.gov.cn/gongbao/content/2021/content_5595926.htm
A brand with no company in China borrows someone else’s. The importer already has an entity and already clears your goods. So the distributor ends up with the role, usually as one line in the distribution deal.
Its name then goes on every pack you import.
Where the registrant or filer is an overseas company, the Chinese label must also show the domestic responsible person’s name and address. Source: NMPA (国家药监局), Cosmetics Labeling Measures, Announcement No. 77 of 2021, article 7, May 2021. https://www.gov.cn/gongbao/content/2021/content_5631831.htm
The job also carries legal exposure.
A domestic responsible person that fails to assist with adverse reaction monitoring or recalls faces a fine of 20,000 to 100,000 RMB, or 100,000 to 500,000 RMB in serious cases. Source: State Council (国务院), Cosmetics Supervision and Administration Regulation, Decree No. 727, article 70, June 2020. https://www.gov.cn/gongbao/content/2020/content_5525087.htm
The old rule gave your distributor a veto
From May 2021, a change of responsible person ran through article 48 of the NMPA’s rules on filing documents. It asked for three things. Two were easy. The third was the old partner’s signature.
Changing the domestic responsible person required the product list, the original responsible person’s sealed consent letter or an effective judgment proving the change, and the new responsible person’s commitment. Source: NMPA (国家药监局), Provisions on Cosmetics Registration and Filing Documents, Announcement No. 32 of 2021, article 48, via the Fujian Provincial Medical Products Administration, June 2021. https://yjj.scjgj.fujian.gov.cn/hzp/flfg/202106/t20210608_5616054.htm
A distributor being replaced has stock in its warehouse and no reason to hurry. Without its company seal, your new partner couldn’t take over the filings. The only other road was a lawsuit, on the court’s calendar. The same rules hold new imports until a change is complete, so general-trade shipments waited too.
What Announcement 70 changes
We read this against the NMPA’s own text on September 24, 2026. Item 8 strikes the consent letter and the judgment. In their place goes the authorization letter, original plus notarization, which the brand signs. The old partner isn’t asked.
The change removes a procedural obstacle for companies adjusting commercial cooperation and lets registrants and filers decide for themselves as the market moves. Source: NMPA (国家药监局), policy interpretation of Announcement No. 70, July 2026. https://www.nmpa.gov.cn/xxgk/zhcjd/zhcjdhzhp/20260729120327100.html
Look at the third document. The new responsible person takes on the old one’s responsibilities for products already on the market before the switch. Your incoming partner inherits liability for stock it never imported, so expect questions before it signs.
Changing a domestic responsible person, before and after
| Step | Article 48 rule (May 1, 2021 to July 28, 2026) | Announcement 70 (from July 29, 2026) |
|---|---|---|
| What the brand files | 3 documents: product list, old partner’s consent letter or a judgment, new partner’s commitment | 3 documents: notarized authorization letter, product list, new partner’s commitment |
| Whose consent | The old partner’s, under its company seal, or a court’s | The brand’s own, through the authorization letter |
| Typical timing | Open-ended: as long as the old partner held back its seal, or a lawsuit ran to judgment | No wait on the old partner; notarizing the letter sets the pace |
| What the old partner can block | The change itself | The filing change: nothing. Its stock and disputed invoices: whatever the contract lets it |
| Stock imported before the change | Sells until the end of its shelf life | Unchanged |
| New imports | Wait until the change is complete, then carry the new partner’s name and address | Unchanged |
The last two rows come from article 38 of the 2021 document rules and the labeling rule quoted above. Announcement 70 leaves both alone, and neither text sets a processing time for the change.
What to put in the next distribution contract anyway
Your old partner has lost its grip on the filing. Plenty else is still open, and four clauses are worth the argument.
- An authorization term that matches the contract. The 2021 rules make the letter state its scope and term, and a responsible person whose letter has expired can’t file new products for you. Line up the end dates.
- Record handover on exit. Every adverse reaction report and batch record for goods the partner imported, within a set number of days. Your next partner signs for that history.
- Recall cooperation that survives termination, for goods the old partner put on the market.
- A sell-off plan. Who sells the old-label stock, or whether you buy it back and at what price.
Keep copies of every filing record yourself. Announcement 70 changed the filing, while termination still runs on your contract and whatever notice it requires.
Where this fits in a partner switch
Sign the new partner before you tell the old one. Issue the notarized authorization, then let the new partner file the change with the product list and its commitment. Old stock sells through, and whatever ships after the change lands with the new name on the label.
The gap in between is where brands lose shelf time. A cross-border store can bridge it, because goods sold on Tmall Global, JD Worldwide or Douyin under cross-border retail import rules need no NMPA filing, so they need no responsible person either.
Cross-border retail imports are supervised as goods for personal use, so first-import permit, registration and filing requirements do not apply. Source: MOFCOM and five other bodies (商务部等六部门), Notice 486 of 2018, article 3, November 2018. https://www.gov.cn/zhengce/zhengceku/2018-12/31/content_5437823.htm
Opening that route for skincare isn’t free.
A cross-border skincare store needs 80,000 RMB in cash before the first sale on Tmall Global, 42,600 RMB on JD Worldwide and 5,000 RMB on Douyin cross-border, deposits and annual fees included. Source: TheChinaPath calculator data, September 2026.
Douyin Global’s base deposit follows last month’s sales, up to 5,000 RMB. Source: Douyin E-commerce (抖音电商), Douyin Global deposit rules, June 2025. https://school.jinritemai.com/doudian/web/articlev0/107821
Whether to keep a distributor at all, or run cross-border setup yourself, is priced out in China distributor vs own store. If you’re keeping one, the guide to finding a distributor in China covers the vetting, and Compass holds the partners we’ve checked.
Quick answers on the switch
Does my old distributor have to agree to the change?
Not for the NMPA filing. Since July 29, 2026, the old partner’s seal is off the list of documents. If your contract requires notice before termination, give it.
Does this cover special cosmetics as well as general ones?
Yes. Item 8 applies to any product changing its responsible person, and the old article 48 sat in a chapter covering registered special cosmetics and filed general ones. A sunscreen or a hair dye needs the same three documents as a cleanser.
Can two partners hold the role while we switch?
No. The 2021 document rules bar a product from authorizing more than one domestic responsible person. The handover is a clean cut, so set the date around your shipping calendar.
If your filings sit with a partner you’re thinking of replacing, request a Compass shortlist of distributors for your category.
Updated September 24, 2026
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